About the guidelines
EWC strives to be a place where workers as well as those who are involved in our activities shall feel safe.
According to the Norwegian Working Environment Act § 2 A-6, employers must have internal procedures in place or initiate other measures that can facilitate the reporting of unacceptable behavior and/or misconduct in the workplace.
According to the Equality and Anti-Discrimination act § 13, any kind of harassment is prohibited. As an employer, EWC has a responsibility to avert and seek to prevent harassment and sexual harassment in our area of responsibility.
The purpose of these guidelines is to provide those involved in EWC’s work with greater transparency as to when and how one can report instances of misconduct or unacceptable behavior.
To whom do these guidelines apply?
These guidelines apply to all EWC employees, consultants, partners and participants involved in EWC activities.
Why should you report misconduct and unacceptable behavior?
When receiving information about misconduct, the management can handle the situation. Some measures can be implemented then and there, while other situations require thorough investigation and follow-up.
Misconduct can be linked to the use or abuse of formal or informal power. A potential power imbalance between the parties involved can affect the degree of severity. At the same time, power imbalance might make whistleblowing feel more difficult. EWC encourages all to take this into consideration when experiencing or witnessing misconduct.
Reporting will contribute to preventing illegal activities and other forms of misconduct, which will again contribute to a better working and learning environment. Your information could help to reach this goal.
What should be reported?
• Illegal conduct or activities1
• Conditions that constitute a danger to life and health
• Bullying, harassment, sexual harassment, and discrimination
• Financial fraud
• Violation of EWC ethical guidelines
• Other unacceptable conditions
Some definitions
Harassment and bullying: Harassment is when someone is subjected to unwanted negative behavior, exclusion or utterances that seem or are intended to be offensive, frightening, hostile, degrading or humiliating for example on the basis of gender, ethnicity, religion, disability, sexual orientation or age.
Harassment can further be bothering, ostracism or hurtful teasing. Harassment can be both a one-off incident and may occur repeatedly. If a one-off incident, it must be of a certain degree of severity to fall under the term harassment. However, if negative and offensive behavior occurs systematically and repeatedly over time, it would rather be considered bullying, which is a form of harassment.
Note that what is deemed harassment also depends on the effect caused, not only the intention2.
Sexual harassment: Sexual harassment means any form of unwanted sexual attention that has the purpose or effect of being offensive, frightening, hostile, degrading, humiliating or troublesome. Sexual harassment includes verbal, nonverbal and / or physical contact ranging from misguided jokes / communication, to extortion, rape, and other sexual acts.
Note that what is deemed sexual harassment also depends on the effect caused, not only the intention3.
Discrimination: Discrimination is the same as inequal treatment. Grounds for discrimination can be gender, ethnicity, religion, disability, sexual orientation, or age.
Financial misconduct: Financial misconduct may involve situations where people use their position for their own gain and to the detriment of the EWC. It may be use of the establishment of a competing organization, mishandling of funds, fraudulent billing, theft of money from EWC accounts or non-disclosure of damage to EWC property.
Negative organizational culture: A negative organizational culture can develop when unethical behavior, backbiting, internal humor that seems exclusive, profanity or gossip occurs. There may be people who behave in a manipulative way, who break confidentiality or situations where criminal behavior is covered up because of friendship. There may be events that are hushed up or it can happen that someone comes with false reports to strengthen their own position.
Alcohol or other substance abuse: Social events and other activities at the EWC must be inclusive for everyone involved, and it is an aim that as many as possible will attend. In such contexts, the consumption of alcohol and the consequences of such can be excluding and experienced as uncomfortable by some. The EWC wants alcohol to be enjoyed in moderation at events organized by the organization. Events for children and young people are totally alcohol free.
Reporting when children are involved
Complaints or reports might in some cases involve children under 18. Particular consideration should be given to the following.
Note that if there is justified reason to believe that the child has been involved in a criminal offence (as a victim, perpetrator or witness), the police should be contacted as soon as possible to advise on further action.
• Who does the child feel comfortable talking to? It might be better that someone who knows the child conducts out the initial talk.
• Are additional resources required to conduct conversations with the child?
• Is the child above or below criminal age (15) / age of consent (16) / legal age of majority (16)? Should parents be involved?
• The child’s interests and his/her right to be heard. The child has the right to speak and for his/her opinion to be given great weight. The committee must be particularly responsive to the child’s own interests and needs.
How do you report?
In general, you shall report to your nearest leader. You can report by email, telephone or verbally. To pursue a complaint, EWC will usually need your contact information. However, it is possible to report anonymously via EWC’s secure portal: see link in document below.
When reporting (including when reporting anonymously) you use the form below.
It is an advantage that you give as precise a description as possible of the case:
- What you are alleging or reporting
- Where and when the incident happened or what you have observed over time
- Who is involved /witnesses
- Any information regarding previous incidents
Who is handling the report?
All reported cases shall be handled in a responsible manner. At the EWC, reports will primarily be handled by a reporting committee. The committee constitutes of the Executive Director and the Chief Financial Officer. Depending on where the report comes from, the relevant Head of Section will join the committee. If a report involves an EWC staff member, he/she will not be involved in handling that specific case.
EWC will investigate and assess if what has occurred is to be considered a misuse of trust. If there is justified reason to believe that someone has committed or been subject to a criminal offence, the police should be contacted as soon as possible to advise on further action.
How is the report handled?
The process of handling a report generally consists of the following four steps:
1) Assess the report and consider if this should be reported to the police
2) Individual meetings with both parties to find out what happened
3) Conclusion and assess potential consequences for the person who is reported
4) Take action and follow-up on the conclusion
Fundamental principles for the committee when handling reported cases are confidentiality (not to share confidential information), impartiality (to be impartial and to not have personal interests in the case), and contradiction (that the person who is reported gets the opportunity to explain about what they are accused for).
EWC has a responsibility to attend both to the person who reports and the person who is reported.